Rocky Flats Site Profile Review: 

Matrix of priority Issues potentially relevant to SEC petition review 

Prepared by ABRWH Workgroup, Jan 8, 2007 

(See Oct 31, 2006 matrix for previous action items) 

Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 1 of 15 

Comment 

Number Issue Description Actions (Aug 31, 2006) 

2 The approaches regarding solubility need to 

be reviewed, particularly for Type “S” or “super-S” plutonium compounds whose high insolubility may lead to more exposure to gastrointestinal and respiratory tract organs. The sensitivity of the bioassay methods was not adequate to detect incidental intakes of insoluble compounds, and also the bioassay methods applied at that time were not appropriate. 

1a. NIOSH provided TIB-0049 and all supporting case data and a

TIB-0049. SC&A has completed review and will include in SEC ev#0030) 

1b. NIOSH provided all data and analysis related to USTUR auto

of the Super S plutonium approach. 

1c. NIOSH provided procedure for addressing GI tract doses from 

exposures. SC&A to review and incorporate in review of evaluation 

1d. NIOSH to provide identifiers for all design cases and NIOSH 

HAN-1 case. 

1e. NIOSH provided identifiers for 25 cases (cases with highest lu

1965 fire. SC&A compared these cases with cases used in OTIB-00

1f. NIOSH will provide HIS-20 with identifiers (name, SSN, and SC&A reviewed several of the individuals (25 cases in 1e above) 

data in electronic data. SC&A requested the hard copy radiation fileNIOSH indicated that they don’t have these files but would request 

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Rocky Flats Site Profile Review: 

Matrix of priority Issues potentially relevant to SEC petition review 

Prepared by ABRWH Workgroup, Jan 8, 2007 

(See Oct 31, 2006 matrix for previous action items) 

Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 2 of 15 

4 Uncertainties are not addressed in the TBD 

regarding the 241Am assay of plutonium 

processed at RFP and how lung counting was calibrated to these values, especially in view of different 241Am proportions at different 

processing steps and different plutonium ages. 

1. NIOSH believes approach was adequately described in the site prexplanation of approach and presentation of additional information radjusting plutonium isotopic ratios and Am in-growth, SC&A agreeratios cited may be appropriate. NIOSH provided some information to support the assertions regardi

adjusting plutonium isotopic ratios and Americium in-growth to the review. 2. NIOSH to outline approach for determining internal dose from Amimportant for Americium separation operations prior to implementatprogram). 3. Upon further research NIOSH indicated that Americium separatiplace prior to 1963 and post 1963 workers involved in Americium swould have had Americium specific bioassay testing. (‘other radionfinding #35) 4. NIOSH provided report on “other” radionuclides at RFP which in

Americium-241. SC&A provided a review of this report. NIOSH pinformation on other radionuclide use (see item 29 and 35 below) 

6 Interpretation of NTA film data and 

correction of recorded dose for workers who were not included in the NDRP is not evident. 

1. NIOSH has provided (on “O”drive) the NDRP data and OTIB-00and provide comments. SC&A has raised a number of questions sen2006 after a brief look at the NDRP report. Some of these questions such as the justification for using the NTA film calibration factor foview of the problems with the latter and using one or two neutron caall neutron energy spectra in the varied workplaces at RFP. SC&A 

mtg) that they are satisfied with NIOSHs explanation of the calibratprovide to SC&A for review the details for early neutron dose data u1 in OTIB-0058 per Ron Buchanan review comments (5/26/06). NIbeen included in draft revision of TIB-0058. NIOSH provided report outlining the QA of the NDRP database. (10See also, item #23. 

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Prepared by ABRWH Workgroup, Jan 8, 2007 

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RFP Issues Matrix page 3 of 15 

7 There is a need to use neutron-to-photon 

ratios and/or film/TLD comparisons to correctly determine past neutron doses. Workers were exposed to neutrons in the NTA film period at lower energy levels than the dosimeter is capable of measuring. It is important to generate correction factors for under-monitored workers or for monitoredworker missed dose. This is especially important for non-Pu workers covered by the NDRP Report, and workers involved with the Pu tetraflouride and Pu machining operations during the early period. 

1. NIOSH provided Plutonium tetraflouride calibration information documents to the Board and SC&A 

9 The site profile, while incorporating 

methodologies for assignment of missed dose, has not adequately bound exposure conditions, compensated for calibration errors and technical deficiencies, and addressed possible data integrity issues, including possible zero entries in the dose records when badges were not returned, all of which may contribute to missed dose. 

1. NIOSH has provided the NDRP data (available on the “O” driv

developed OTIB-0050 which describes how to use NDRP data for inreviewed and NIOSH responded. No further actions. 

2. NIOSH continues to pursue obtaining the Job-Exposure Matrix 

Ruttenber however, NIOSH believes this is not an SEC petition issu

3. NIOSH provided analysis regarding the ‘completeness of exter

SC&A will review and provide comments in the review of the SEC (SEC #0030). In the interim, SC&A provided an analysis of remain

Ron Buchanan, SC&A). SC&A has concerns about potential gaps iof records with ‘zero’ dose in 1969 and 1970. NIOSH indicated tharecords of 600 claimants and determined that 138 have records whicfor 1969. NIOSH will provide the following documents related to thfor the time of the fire, 2) Incident report(s) for the fire. NIOSH has the time period and is in the process of comparing these with the data logbook from the time of the fire (being transmitted). NIOSH posted the individuals lung counted after the 69 fire on the O SC&A to review individual radiation files of individuals to determinincluded. 

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Rocky Flats Site Profile Review: 

Matrix of priority Issues potentially relevant to SEC petition review 

Prepared by ABRWH Workgroup, Jan 8, 2007 

(See Oct 31, 2006 matrix for previous action items) 

Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 4 of 15 

NIOSH provided a report on the 1969-1970 missing data issue, 10/3SC&A in the process of reviewing this report. 

4. NIOSH will provide description of co-worker model to be used 

worker database and/or analysis files. NIOSH indicated that few caworker data. SCA will review and comment on approach in the revireport (SEC #0030). 

5. NIOSH indicated that it is not clear that ‘the practice of record

were not turned in ..” was consistent across all time periods". NIOSpractice over time and provide an assessment to the Board and SC&that "[i]nconsistent procedures for monitoring and dose assessment" also asserts that after neutron monitoring was introduced, the readinerror" until the 1970s and that dosimeter chips were sometimes "desprocessing." (p. 13) These allegations should be addressed in NIOSFurther petitioners claimed during the Feb 27 workgroup meeting thnot wearing badges because of hazard pay incentives. NIOSH has phandling these type of instances. SC&A will review as it applies to question. NIOSH has sent a letter to the petitioners requesting morare waiting for a reply. The petitioners indicated that a letter was re(Items listed here have been listed separately in the matrix (see n6. NIOSH needs to research this question further (inappropriate lowcorrection factor that may have been used as stated in 1993 DNFSB provided a response indicating that the response of the Panasonic doFlats was based on the response to several spectra and was not affecDOELAP testing program. No further action required. 

7. NIOSH will determine the extent and nature of the ‘criminal in

‘security investigations’ mentioned by the petitioner during the worksent a letter to petitioners asking for more specifics. NIOSH receiveand provided a written response to several items (document titled “SNIOSH Action Items” dated April 20, 2006). NIOSH found nothing point. 

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Prepared by ABRWH Workgroup, Jan 8, 2007 

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Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 5 of 15 

8. NIOSH / ORAU to demonstrate reliability of bioassay and exte

compensation program. NIOSH reported that Kaiser Hill did QC exthe database when assembling individual claimants data. No roll-up NIOSH provided additional analysis within the SEC evaluation reposupplemental materials. NIOSH compared records from 38 claimandatabase and determined that there was good agreement (see documRocky Flats NIOSH Action Items” dated April 20, 2006). NIOSH nwould have bioassay card data for data prior to 1969. Post 1969 the database printouts (HSDS or HIS20 database data) rather than bioasin the process of retrieving urinalysis logs for comparison to databasmethodology for sampling from the raw records for comparison to tprovided urinalysis logs on the O drive and NIOSH provided an anacompared to individual radiation files. 

NIOSH provided report on HIS-20 lung count data (8/23/06) which substantial problems with HIS-20 lung count data. NIOSH provided report comparing HIS-20 urine data with CER urinthat there were large discrepancies but pointed out that the dose recovast majority of the cases, will not rely on these database data (10/6/

10 

(formerly 

numbered New 

Issue #1) 

Only “roll-up” penetrating doses exist for individuals prior to 1976. It is not clear how the neutron and photon doses will be determined from the roll-up dose. 

NIOSH proposes to use the approach used in NDRP and outlined in determinations and for 1971-1976 a proposed neutron to photon appOTIB-0050 will be used. SC&A will review these proposed approacomments. No further action required. 

11 

(formerly 

numbered New 

Issue #2) 

A group of results from July thru October 1984 appear to indicate a reporting problem with the dosimetry algorithm used to calculate dose equivalents 

NIOSH indicated that the problem with the algorithm resulted in recevaluated as zeros, with higher doses and therefore concludes that it claimant favorable determination. No further action necessary. 

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Rocky Flats Site Profile Review: 

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Prepared by ABRWH Workgroup, Jan 8, 2007 

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Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 6 of 15 

12 Zero entries in dose record when badges 

were not returned (Matrix comment number 9) This issue is divided into two periods: 

 Pre-1964, when badges were not 

issued to all workers 

 1964 and after when badges were 

issued to all workers 

The dose record may also contain blanks or “no data available.” Methods to separate these kinds of entries or blanks from zeros that denote a value below the LoD are needed. 

NIOSH will track specific ‘no data available’ cases and will review 

whether there is a systemic problem. NIOSH attempted some statistpotential systemic problem using claimant data however, due to the with other factors this analysis was inconclusive. SC&A has conducindividuals at the site and has recovered some materials (log books, topic. SC&A provided a report outlining some of these data integrittitled “Interim Evaluation of Data Reliability Issues: Needed DocumEvaluation” dated April 19, 2006). Follow-up actions from this repoitems 30, 31, and 32 at the bottom of this matrix. NIOSH has obtain1973 and is in the process of comparing ‘no data available entries’ w

NIOSH provided analysis in file ‘no current data available.pdf’ on 8SC&A reviewed 12 individual claim files for completeness. SC&A (10/24/06). SC&A to draft sampling approach to be used in sampling from ALL up to 1993 (D&D era); SC&A and NIOSH to review proposed apprgoals of workgroup will be met. It was agreed that radiation files fowould be reviewed and additional randomly selected cases (less than cases). SC&A to provide draft report to Emily Howell for privacy 

13 Chips fell out of TLDs and readings were not 

included in worker records. Allegation in SEC petition. 

These situations were probably not investigated. NIOSH determinethere was a procedure but only to take problems to a supervisor but chips concern could have only been during the period of 1969-1983 badges were used. SC&A provided the badge numbers to NIOSH fo

against HIS-20 database. NIOSH provided response in file ‘dosime8-25-06.xls’. SC&A to review and include in overall evaluation rep

14 Hair and body oils on TLD chips cause 

inaccurate readings (SEC Part a, p. 45) 

Oil or dirt contamination on a crystal could burn as the crystal was h

artificially-high result for that crystal. This result, when compared wother crystals in the dosimeter (Figure 1), would have indicated whebeen exposed to contamination. In this case, the result from that crydose could be estimated from the readings from the remaining crystaAnomalous TLD results were investigated using, and the procedures formalized in 4-J88-RDE-0053, "TLD Data Investigation and Abbre

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Rocky Flats Site Profile Review: 

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Prepared by ABRWH Workgroup, Jan 8, 2007 

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Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 7 of 15 

Reconstruction" and 4-J98-RDE-0071, "Extended External Dose Rewill determine if a procedure similar to the one mentioned above wa

history of the site and NIOSH will provide the procedures. NIOSH badge which required handling of the chips was used from 1969-198

1983 procedure which discussed appropriate handling No further areview and include in overall evaluation report. 

15 Deliberately false entries were made into 

dose records There is a charge of deliberate falsification of data. For instance, a worker alleges that his supervisor “would advise the dosimeter worker that the dose shown was too high to be possibly correct,” and the worker was advised to change or delete the reading. (SEC petition, Part a, p. 57.). Further in Part b, p. 501, a worker alleges that zeros were entered into dose records when the TLD reader failed. 

NIOSH is not currently aware of any findings of systematic falsif

serious charge has been made by the petitioner at previous working letter dated March 15, 2006, (Figure 2) NIOSH followed up with the 

any supporting investigation reports that could be provided. NIOSH petitioner and provided a written response to several items (documeFlats NIOSH Action Items” dated April 20, 2006). NOTE: This ite

comment 9, action item 7 above. NIOSH will follow-up by reviewi(representative number) to check for indications of abnormal findingdatabase. NIOSH provided a report on review of log books. SC&A to review and include in overall evaluation report. 

16 Unauthorized work practices 

The petition provides examples of unauthorized work practices (e.g., p. 54, Part a) 

While such practices constitute a regulatory compliance violation, nthat such occurrences would prevent dose reconstruction of sufficienaction required. 

SC&A to review and include in overall evaluation report. 

17 Inappropriate subtraction of background in 

badges hung in the hallway of a work area (alleged in SEC petition) 

Approximately 18 boxes of external dosimetry program records werrecords included weekly and monthly status reports from the 1950s, some technical documents generated during that period. Approximadocuments were identified as potentially relevant to this issue. No ehigh background problem was found. In the worst case, such a situaadjustment to the ambient environmental dose NIOSH assigns durinwould not preclude accurate dose reconstruction. Therefore NIOSH does not have SEC implications. No further action required. 

SC&A to review and include in overall evaluation report. 

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Prepared by ABRWH Workgroup, Jan 8, 2007 

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Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 8 of 15 

18 Workers frequently did not wear badges in 

production areas and did not report non-use of badge (Petition, Part a, p. 53) This raises a question of how missed dose is to be interpreted. 

NIOSH provided preliminary statistical analysis (April 20, 2006 resselected since after 1977 badge data rather than summary quarterly dthe database) suggesting that the allegation was not a systemic probl

evaluating the issue. SC&A provided analysis in response at Augusagreed with NIOSH that flattening of cumulative dose curves not sunon-wearing of badges, but SC&A pointed out statistically small nuincluded; closure not achieved. 

19 Badge did not properly record organ dose 

due to organ being closer to the source than the badge or due to workers wearing the badge under their lead aprons. - Petition provides examples where dose to head and other areas would be much greater than badge reading (p. 53, Part a) - Some workers wore their badge under their lead aprons leading to under-recording of doses to some organs, such as the head, arms, and face. (p. 53, Part a, and p. 23 Part b) Note that these examples are also part of the suggestion that co-worker models for Rocky Flats worker external dose would not be valid. 

NIOSH will evaluate the appropriateness of correction factors for vaperiods on the site. NIOSH provided response in 6 April 2006 commAditionally, NIOSH has developed a TIB on glovebox work and is aTBD on correction factors for lead aprons. SC&A agrees with NIOissue. 

20 Missing dose record in areas of high 

exposure One worker has provided an affidavit saying that an entire year’s dose record is missing from a time he worked in an area with radiation dose rates that ranged up to 8 R/hour. He was an [redacted] in the Stacker 

Receiver area of Building 371, and, [redacted], he was not rotated out of the area since he was an [redacted] (Part b, p. 32). A worker affidavit including this problem is provided on p. 539 of Part b. 

NIOSH tracked back specific data for this individual and believes thsupported by the data available in the database (see 5 April 2006 comNIOSH will provide dosimetry data prior to and post the cited time provide any incident or investigation data found in the individual’s d

NIOSH response included in document : “Rocky Flats Plant, Data InAugust 25, 2006. SC&A to review and include in overall evaluation report. 

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Prepared by ABRWH Workgroup, Jan 8, 2007 

(See Oct 31, 2006 matrix for previous action items) 

Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 9 of 15 

21 Bioassays redone when they indicated high 

exposure There are two examples cited that claim that bioassays were redone or individuals were recounted when the readings were high and subsequent results were declared as having no exposure or false positives (Part a, p. 47 and Part b, p. 32) 

If the worker was enrolled in a bioassay program, NIOSH would assbioassay results below the limit of detection, and no evidence has bepractice is insufficient to support sufficiently accurate dose reconstrNIOSH would not exclude ‘false positive’ values from bioassay ana

Identify QA reports and post on O drive if available. NIOSH will fo

cited. 

NIOSH response to specific examples included in document : “RockIntegrity Examples,” August 25, 2006. SC&A to review and include in overall evaluation report. 

22 Instances of “no data available” in situations 

of high exposure There is, for instance, a worker affidavit on 

p. 35 of Part b stating that “no data available” was entered into the record despite the fact that the film badge was blackened with exposure and the work was in a high exposure area – Am-241 processing. By contrast, there were entries for positive dose at a time when the worker was serving in the military in [redacted].

NIOSH is in the process of tracking specific cases. No further actio

23 Most exposed workers were not monitored 

for neutrons The petition cites [redacted] as saying that 

until July 1958, the most exposed workers were not monitored for neutrons (Part a, p. 71), raising a question about how the neutron data in the NDRP study are to be used, even if the re-reading of the badges is accepted as sound. 

Neutron doses can be calculated based on neutron dosimetry if availNeutron Dose Reconstruction Project. If neutron dosimetry is unavneutron/gamma ratios can be used to calculate neutron doses. The Ntechnical documentation (OTIB-0050) provide time-varying (and loNDRP data) neutron to photon ratios. Application of these results to documented in OTIB-0050 and the dose reconstruction instructions. The lack of neutron monitoring in the early years does not prevent Ndose reconstructions of sufficient accuracy, and can be dealt with by gamma ratios. NIOSH is not aware of any evidence that would call 

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(See Oct 31, 2006 matrix for previous action items) 

Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 10 of 15 

badge re-reads conducted in the NDRP study into question. SCA w

approach and incorporate in review of SEC evaluation report. NIOSfurther with specific attention to whether it is appropriate to use n / p periods for earlier time periods (was source term, operations and shiboth time periods in question (70s and early 50s). After further discseveral additional actions were identified: 1. NIOSH to provide identifiers for HIS-20 database. 2. NIOSH to correct table 7-1 and 7-2 in TIB-0058. This is in revise3. NIOSH to expand explanation of technical basis for n/p ratios in 5draft. 4. NIOSH to provide background for NDRP report table 1.1. 5. NIOSH to ‘spotcheck’ co-worker method by comparing calculatedoses. 6. NIOSH to provide ‘benchmark’ n/p ratios in 50s and 70s (per abo7. NIOSH to possibly consider alternative coworker model. 

24 Neutron badge reading was defective 

Part a, p. 77 shows that zero entries in neutron dose reading dropped from 95.6 percent in 1961 to 56 percent in 1962. So this raises issue of quality of reading badges in the earlier period. 

The comment is correct that the observation of the change in zero en

readings between 1961 and 1962 raised questions about reading neuobservation was the motivation behind the Neutron Dose Reconstrunot aware of any issue which would call into question the re-reading conducted under the NDRP. No further action required. 

25 Post 1991 worker monitoring was not 

according to criteria for security guards Not all workers were badged in the post-1991 period – only those who were thought to have potential for more than 100 mrem exposure per quarter were badged. The DNFSB found that security guards had the potential for greater exposure but were not monitored. This raises the issue of how dose is to be assigned to post1991 unmonitored workers, if 100 mrem cannot be reliably and consistently regarded as an upper limit missed dose. (Part a, p. 122) 

NIOSH believes co-worker approach would address this issue. No f

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RFP Issues Matrix page 11 of 15 

26 Many incidents were not reported or 

recorded. The petition claims, “throughout the history of the site it was common practice for incidents in the workplace to be handled at the floor or building level and not reported” (Part a, p. 19). This goes to whether missed internal dose due to unreported and unrecorded incidents causes a problem in regard to adequacy of data for dose reconstruction. Tab E.5 has a detailed example of this and refers to others. Also, p. 139, Part a, cites an unreported incident 

discovered during a routine bioassay. There are other examples of undocumented exposures in the pages that follow. p. 179; Part a is an example of a worker who was in an explosion involving Pu but there is no film badge. 

NIOSH indicated they will estimate dose based on individuals persoworkers were on a routine bioassay program. For un-monitored workers, NIOSH contends that exposures from inby co-worker approach. The draft co-worker TIBs, along with the sprovided to the Board and SC&A. 

SC&A reviewed TIB-0038 and had several questions which were diworkgroup meeting. NIOSH provided ‘white paper’ which further dfor co-worker model in TIB-0038. SC&A provided a response to thAllen, NIOSH, in turn, has responded on 10/30 that issue is not with application in the TBD. 

27 Is data sufficient for estimating ingestion 

doses? Workers ate in workplaces. One investigation concluded that there was ingestion via inhalation (p. 88 onwards in Part a). How are bioassay data to be interpreted in light of this problem? Also ingestion may have occurred via resuspension. The relevance of this is in the context of deposition of high-fired Pu in large parts of the plant due to the major fires. 

This is not an issue since all assessments will be based on bioassay dnecessary. 

28 Worker alleges that work-week was logged 

as 40 hours when it was 45 hours (Part b, p. 24). 

NIOSH indicated that they would not be using air sampling to determ

the length of the work week would not affect the dose reconstructionnecessary. 

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RFP Issues Matrix page 12 of 15 

29 Concern over potential exposures to other 

radionuclides. There were potentials for occupational exposure to tritium (gas, HTO and others), 233U, 241Am, 237Np, 244Cm and 

210Po. Purification of 241Am began in 1962 

and continued to 1979. 233U processing at 

RFP was conducted from 1965-1982. Operations involving 233U included metal 

processing, component manufacturing, material recover, and waste handling. Curium, neptunium, and polonium were used as tracer for the purpose of testing components and were handled in small quantities. 

NIOSH response is in SEC petition evaluation report and in 5 April document (page 40). NIOSH provided additional information regarradionuclides. SC&A provided reponse to the two documents. NIOnotes from site expert regarding other radionuclides present over timinterview). NIOSH later provided interview notes from other site ex

See also, item #35. 

30 Safety Concern Reports identified which 

indicate concerns with dosimetry results 

NIOSH will retrieve safety reports identified by SC&A, provide the SC&A and attempt to track back to the specific individual. SC&A w

reports. NIOSH reviewed the identified reports and found that eithe

not related to the issue of dosimetry results or that the concern cited appear to have merit. NIOSH agreed to review the entire database odetermine if there were other safety reports which should be reviewea listing of safety reports (1970 – 2000) and has selected several froSC&A will review list and determine if other documents are of inter

NIOSH know which other documents. NIOSH provided review of 3(identified by NIOSH) and review of 17 additional safety concern reSC&A). NIOSH concluded that there were no findings related to SEprocess of reviewing NIOSHs report. 

31 Concerns were expressed over discrepancies 

between log books and personnel dosimetry records. 

NIOSH will review specific cases identified by SC&A for the 1985-NIOSH will attempt to retrieve similar log books from the film and 

periods and evaluate the possibility of follow-up from those reports. and scanned a sampling of these log books for review. NIOSH post

books on the O drive. NIOSH provided a report comparing data in log books with individu

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Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 13 of 15 

(10/27/06). SC&A in process of completing review of NIOSH report. See also, item 32, item 34, and item 9-8. 

32 Concern that secondary dosimetry logs, 

contamination control logs, or foreman logs include exposure information (possibly individual specific data) which is inconsistent with individual personnel dosimetry records 

NIOSH will attempt to retrieve and review records identified by SCBoard and SC&A and evaluate the possibility of follow-up from thowhether information is available which could be used to determine tdosimetry records). NIOSH has recovered and scanned a sampling review. NIOSH has agreed to post the copies of these log books on sample from three different types of logs, from the 70s to 2000 for p

concern (uranium, production, decon). NIOSH provided a report rebook results and records contained in individual radiation files (10/2SC&A in process of completing review of NIOSH report. See also, item 31, item 34, and item 9-8. 

33 Concern was raised as to whether adequate 

information was available for reconstructing internal doses for D&D workers (including all subcontractors). 

NIOSHs believes that the bioassay program during D&D operations which would be sufficient to reconstruct internal doses. NIOSH has 

available data for the D&D workers. NIOSH will review RWII trainroster for the D&D time period and compare against HIS-20 to deter(including subcontractor workers) were in routine bioassay programinternal dose audit reports from the D&D time period. SC&A provi(from Joe Fitzgerald, 10/24/06). SC&A found that many D&D workers did not leave termination biothe question of whether internal doses for such individuals could be NIOSH provided analysis indicating that a co-worker model (extensbe used for these workers. This analysis included a comparison of tbetween representative top-tier contractors and D&D subcontractors significant difference in dose distribution, thereby substantiating the RFP dose data to dose estimation for unmonitored D&D workers. SC&A in the process of reviewing this analysis. 

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RFP Issues Matrix page 14 of 15 

34 NIOSH Site profile indicates that urinalysis 

log books are available for purposes of assessing MDAs. These log books may be useful in assessing the reliability of the electronic data. 

NIOSH will attempt to retrieve the log books and outline an approacassessing the reliability of the electronic data. 

NIOSH retrieved and posted some urinalysis log books. NIOSH prodata from all types of log books compared with individual radiation SC&A in process of completing review of NIOSH report. See also, item 31, item 32, and item 9-8. 

35 Concerns raised about whether other 

radionuclides which were not specifically monitored for were an exposure concern. Radionuclides include: Th-232, U-233, Cm244, Np-237, Am-241, Pu-238, and Po-210. 

1. NIOSH / ORAU researched the materials accounting logs to deterand the locations where the materials would have been used. NIOSH workgroup and SC&A. Radionuclides listed include: Th-232, U-23238, Pu-242, and Cf-252. SC&A will review source listing. NIOSH 

which will be used to reconstruct doses from each radionuclide, whe

provided additional information regarding Thorium and other radionand provided a response. SC&A agreed with NIOSHs approach for reconstructing dose for N NIOSH to provide a semi-empirical validation of thorium intake mestimated using NUREG-1400 approach). NIOSH provided final doapproach for Thorium on 12/27/06 (with some clarifications sent by  (also listed in item # 29) 

36 An allegation was made that records related 

to occupational exposure were brought to the T-690 trailer and than removed and put in a landfill. 

NIOSH has interviewed coworkers in an attempt to investigate this iinvestigate the issue, including follow-up with the individual that m

NIOSH provided a report on this issue (9/25/06). 

NOTICE: This report dated November 3, 2011,has been reviewed to identify and redact any information that is pro

by the Privacy Act 5 USC §552a and has been cleared for distribution. 
Rocky Flats Site Profile Review: 

Matrix of priority Issues potentially relevant to SEC petition review 

Prepared by ABRWH Workgroup, Jan 8, 2007 

(See Oct 31, 2006 matrix for previous action items) 

Note: Additional issues may arise as a result the review of the petition and amendments and NIOSHs eva

RFP Issues Matrix page 15 of 15 

NOTICE: This report dated November 3, 2011,has been reviewed to identify and redact any information that is pro

by the Privacy Act 5 USC §552a and has been cleared for distribution. 

37 Other Specific data integrity concerns (not 

detailed in above actions), including: 

 [Redacted] case 

 neutron film blackening 

NIOSH has compiled all identified allegations and concerns into “RIntegrity Examples,” August 25, 2006, which provides specific concNIOSH’s evaluation of that concern. SC&A has reviewed this compsomewhat overlaps prior data reliability matrix items) and will addrreport.